NEW YORK, NY—August 3, 2026—FAIR Health NSA (No Suprises Act) and allowed amount data products may be submitted by payers and providers for consideration by certified independent dispute resolution entities (IDREs) in the federal NSA IDR process; IDREs may also consult FAIR Health data to validate such submissions. Find out more about the federal NSA IDR process here.
Why Use FAIR Health Data in IDR?
Neutrality. FAIR Health is regarded as a fair and neutral provider of robust data and data tools by diverse stakeholders throughout the healthcare sector. IDREs need unbiased data with which to validate offers, and all parties can benefit from a neutral source of data to contextualize such offers. FAIR Health benchmark data are such a source.
Broadly representative. FAIR Health benchmarks come from healthcare claims, including claims from self-funded plans. FAIR Health benchmark data also reflect the distribution of allowed amounts across all 50 states; Washington, DC; Puerto Rico; and the US Virgin Islands. Because of the size and breadth of the FAIR Health collection, our data are representative of all geographies and are therefore well suited to the task of informing NSA IDR.
Contextual detail. FAIR Health benchmark data are created from real-world claims data, as opposed to fee schedules or transparency files, which do not reflect the breadth of actual claims data. Because FAIR Health data reflect this real-world experience, they can be a more persuasive standard and a better reflection of actual contracted amounts for healthcare services around the country. FAIR Health benchmark data can, for example, help put contracted rates in context with other paid amounts for the same service in the same geography.
FAIR Health Benchmark Data
FAIR Health’s database (FH NPIC®) is the largest collection of commercial healthcare claim records in the nation and forms the basis for a suite of benchmark products, FH® Benchmarks, which include the FH® NSA Reference File and FH® Allowed Benchmarks.[1]
- The FH NSA Reference File was expressly created to support compliance with the federal NSA IDR process. It consists of a set of median in-network allowed amount values based on medical billing codes, and the data are available across multiple geographic areas that align with NSA requirements. Find out more about the FH NSA Reference File here.
- FH Allowed Benchmarks include contracted rates between in-network providers and commercial insurers for individual medical, anesthesia, telehealth, inpatient and outpatient services and procedures arrayed from the 50th to the 95th percentile. Find out more about FH Allowed Benchmarks here.
For more information on how FAIR Health data can support the federal NSA IDR process click here.
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[1] FAIR Health also offers a separate set of benchmarks based on provider-billed amounts, FH® Charge Benchmarks, but the NSA specifies that such data may not be used in connection with the NSA IDR process. Parties must make sure they are licensing FH NSA Reference File and/or FH Allowed Benchmarks to submit alongside or compare to offers in IDR.
About FAIR Health
FAIR Health’s mission is to supply objective, unbiased information for all stakeholders to improve healthcare quality, access and affordability. It holds the nation’s largest collection of commercial healthcare claims data, which is growing at a rate of more than four billion claim records a year. A national Qualified Entity certified by CMS, FAIR Health also receives all claims for individuals enrolled in traditional Medicare Parts A, B and D. As a testament to its reliability and objectivity, FAIR Health’s data products—including pricing benchmarks and custom analytics—are widely used by commercial insurers and self-insurers, providers, hospitals and healthcare systems, government, researchers and more. FAIR Health has been designated an official data source for state health programs, including workers’ compensation and personal injury protection (PIP) programs, and surprise billing laws that protect consumers. FAIR Health’s free consumer website and mobile app, available in English and Spanish, enable consumers to estimate and plan for their healthcare expenses and offer a rich educational platform on health insurance. The website has been honored by the White House Summit on Smart Disclosure, the Agency for Healthcare Research and Quality (AHRQ), URAC, the eHealthcare Leadership Awards, appPicker, Employee Benefit News and Kiplinger’s Personal Finance. FAIR Health is a national, 501(c)(3) nonprofit organization. For more information on FAIR Health, visit fairhealth.org.
